Well, to be honest, all filesystems that are currently in the kernel tree started out as being maintained outside the tree. Inclusion into the kernel is normally one of the end goals. It's part of the standard progression - 1) rapid development outside of the tree, 2) once the filesystem is stable, it negotiates for inclusion, 3) inclusion into the kernel, 4) maintenance / updates as part of the main kernel development process.

ZoL isn't even trying to get included into the kernel, so it's a bit of an odd duck here.